Breaking SUPREME COURT REAFFIRMS PUBLIC DOMAIN PROTECTION FOR DIGITAL LAWS
New Delhi · Monday, 21 September 2026 9888666310 | [email protected]
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Supreme Court of India 2017-11-03 dismissed

Chand Devi Daga & Ors vs Manju K. Humatani & Ors

Bench: 2 — Ashok Bhushan

In Brief

In this criminal appeal, the Supreme Court addressed whether legal heirs of a deceased complainant can continue a criminal prosecution. The original complainant filed a complaint against the appellants for offences under the IPC alleging fraud and forgery. After the complaint was dismissed and a revision appeal failed, the complainant died pending a petition before the High Court. The High Court permitted her legal heirs to continue the prosecution. The appellants challenged this order. The Court held that death of a complainant does not automatically abate a criminal proceeding. Under Section 302 of the Criminal Procedure Code, courts may permit legal representatives to continue prosecution on behalf of a deceased complainant in serious criminal matters, subject to court discretion and applicable procedural rules.

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Criminal Procedure Criminal Litigation Standing & Locus Standi Death of Parties Complaint & Revision

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